https://www.taxtmi.com/caselaws?id=466880 Reopening assessments requires recorded reasons to believe and a valid sanction reflecting the sanctioning authority's application of mind; a mere mechanical signature without recorded satisfaction invalidates sanction. Reliance primarily on a district valuer's (DVO) valuation report, being an opinion, does not by itself constitute independent information justifying reassessment absent separate material showing non disclosure or failure to disclose material facts. Where both mechanical sanction and sole reliance on a valuation report are alleged, both defects undermine the assumption of jurisdiction and the belief that income escaped assessment, rendering the reassessment order legally unsustainable in the circumstances described. en-us Wed, 28 Aug 2019 00:00:00 +0530 Tue, 24 Feb 2026 10:14:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466880 Reopening assessments requires recorded reasons to believe and a valid sanction reflecting the sanctioning authority's application of mind; a mere mechanical signature without recorded satisfaction invalidates sanction. Reliance primarily on a district valuer's (DVO) valuation report, being an opinion, does not by itself constitute independent information justifying reassessment absent separate material showing non disclosure or failure to disclose material facts. Where both mechanical sanction and sole reliance on a valuation report are alleged, both defects undermine the assumption of jurisdiction and the belief that income escaped assessment, rendering the reassessment order legally unsustainable in the circumstances described. Case-Laws Income Tax Wed, 28 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466880